Tuesday, 27 March 2018

Comments from SDCEA on offshore oil and gas exploration drilling within block ER2369 of the east coast of KZN

Sasol and
Eni are set to explore the coast of KZN with offshore oil and gas drilling. KZN
is renowned for its famous and beautiful beaches. However, healthy oceans are
critically important to marine life and to coastal communities whose economies
rely on tourism, fishing and recreational activities. Opening up new offshore
areas to drilling, risks permanent damage to our oceans and beaches without
reducing our dependence on oil. KZN’s coast could be subject to huge oil spills
equivalent to the BP oil spill in the Gulf of Mexico in 2010, with calamitous
long-term costs for the tourism and fishing industries. Public Participation is
an important part of legislation, yet this process has been flawed on the
consultant’s part. The coastal community of KZN has been undermined and this
not acceptable.

Impact on the communities, people and
environment

When oil
spills occur they can bring catastrophic harm to marine life and devastating
losses for local businesses. Even routine exploration and drilling activities
bring harm to many marine species. Expanded offshore drilling poses the risk of
oil spills ruining our beaches, bringing harm to those who live, work and
vacation along the coasts, as well as harming habitats critical to plants and
animal species. Oil spills can quickly traverse vast distances. Exploration of
oil and gas presents multiple forms of environmental degradation. These
developments and projects will not only cause catastrophic destruction with the
above-mentioned impacts but will also destroy livelihoods to over 50 000
subsistence fisher folk who eke out a living daily. When seismic tests are
conducted, they clearly have an impact on marine life. The fish are either
killed or forced to leave the area. This impact will increase poverty and lead
to more people joining unemployment line.

Emissions to air

The oil and
gas industry is a significant source of greenhouse gas emissions as well as
toxic volatile organic compounds (VOCs). VOC in combination with NOx contribute
to the formation of ground-level ozone and is a known causal agent of acid
rain. The atmospheric pollution will have measurable impacts on the surrounding
ocean but also become potentially entrapped in air masses moving towards the
coastline where it will be deposited as acid rain. The drilling of wells and
production process require vast amounts of energy usually provided by the
burning of gas and diesel. The impact of this activity needs to be accurately assessed
in terms of tons of fuel burnt and hydrocarbons released. Assuming that oil or
gas is discovered then this would no doubt need to be flared off until such
time as it can be capped and processed. During this time vast quantities of
particulate matter and volatile organic compounds will be released into the
atmosphere, indeed continuing throughout the production process. In addition
the associated fugitive emissions from retrieved product is an additional
source of toxic pollutants as the venting from either onsite (barge/tanker) or
onshore (storage tanks and pipeline valves) must be evaluated. The carbon
generated from flaring will also add to the existing problem and create added
negative consequences in terms of climate change.

South African Coastline

Our
coastline is recognized as being one of the most hostile and formidable to
shipping. Large freak waves, storms and the presence of a year round strong (4
knot) north-south current all spell trouble for any stationery vessel anchored
in place. The impact of the dynamic Agulhas current and its vital role in
important biological processes must be evaluated. The positioning of the rig is
fairly and squarely within this current that is in effect the highway for fish
and mammal species travelling down the Eastern seaboard of South Africa to the
nutrient rich and breeding grounds of the Agulhas bank. Anything that occurs
off KZN coastline will end up being swept to the Agulhas such is the inevitable
nature of the current. It will not simply disperse over the vastness of the
ocean as you are effectively discharging hazardous waste into a fast flowing
offshore river. In addition it is suspected that the south flowing Agulhas
current is of critical importance to the spawning patterns of many fish species
that move northwards inshore up our coastline with larval formations carried
south by the current. Allowing the presence of ecologically destructive
drilling and oil/gas extraction is foolhardy and flies in the face of the
precautionary principle.

Health, safety and rescue
considerations

In this
context consider that the drilling operation lies beyond the rescue envelope of
traditional South African rescue services. South Africa simply does not have
any capability or capacity to provide long distance rescue effort and certainly
not in the weather conditions likely to precipitate a disaster. For example we
have no exiting offshore rescue craft capable of providing a rapid response.
The NSRI is strictly inshore and the naval capability virtually non-existent.
Furthermore, it is not the navy’s role to provide standby services for private
institutions. In addition aerial support also requires specialist aircraft that
South Africa simply does not possess. The key limitations are restrictions
placed on aviation flying over water meaning that specialist aircraft would be
required. Where and what are these and who will fund them? Where will they be
based? Would they really be able to respond in time in order to assist in event
of ecological or human calamity? Consider what occurred on Piper Alpha…and there
you had state of the art first world facilities whereas in South Africa things
are significantly more third world. The odds therefore that a plant upset could
become a runaway uncontrolled event impacting on both life and the environment
are therefore significantly greater than the norm of rigs in the 1st World
North Sea or Gulf of Mexico where, as we know, enormous ecological harm has
been wreaked by this industry despite the proximity of state of the art rescue
and repair facilities.

Impacts of Drilling

Discharges
from drilling consist mainly of crushed material from the borehole (cuttings)
and chemicals used during the operation. In addition brought to the surface is
“produced water” that will contain trace elements of oil assuming oily
condensate is discovered. This requires evaluation. With regard to the drill
cuttings it is not known what alternatives are proposed or whether the cheapest
option of discharge into the nearby ocean is the only option being considered.
For example is it not possible to injecting everything back into suitable
geological formations or take it to shore for further treatment. More drilling
muds and fluids are discharged into the ocean during exploratory drilling than
in developmental drilling because exploratory wells are generally deeper
consequently this is a very real threat to the environment.

Literature
on the discharge of drill cuttings and associated drilling fluids indicate that
it will cause the death of the benthic (bottom-living) organisms living in and
on sediments covered by cuttings in the immediate vicinity of the discharge
point. We therefore would demand that a full survey of such benthic biota is
established prior to the drilling process and that this be monitored as to its
state of health. It is also known that offshore rigs can dump tons of drilling
fluid, metal cuttings, including toxic metals, such as lead chromium and
mercury, as well as carcinogens, such as benzene, into the ocean all of which
must be assessed.

The prospect
of a catastrophic spills and blowouts is a documented threat from offshore
drilling operations and the near impossibility of introducing a successful
capping of the blowout at the depths cited are of deep concern to us. We
require significant detail to be presented on this aspect given the learnings
of the Deep Water Horizon disaster.

The iSimangaliso Wetland Park

The
iSimangaliso Wetland Park is South Africa's very first World Heritage site
since 1999 (Unesco), it is also the third largest protected area in South
Africa. Nelson Mandela stated that “iSimangaliso must be the only place on
the globe where the oldest land mammal (the rhinoceros) and the world's biggest
terrestrial mammal (the elephant) share an ecosystem with the world's oldest
fish (the coelacanth) and the world's biggest marine mammal (the whale)”.

The
consultants are prone to making wild and unsubstantiated and absolutely
unverifiable claims. Consider the following:

“The
Goodlad Canyon differs significantly in morphology from those in Northern KZN,
where coelacanths have been reported and therefore it is unlikely that
coelacanths will be found here”.

How can they
possibly state this? The first coelacanth was discovered in East London off the
Chalumna River. No-one knows where it came from but it certainly did not swim
there all the way from Sodwana bay in Northern Zululand. Almost no exploration
has taken place in the deep canyons and offshore waters of KZN largely on
account of access as there simply are no deep water submersibles available with
which to do so, nor is there any funding. The discovery of the coelacanth off
northern KZN was purely due to the inshore proximity of the canyon that allowed
scuba divers the opportunity of witnessing them. By no stretch of the
imagination can it be concluded that they therefore do not occur elsewhere in
deep waters off our continental shelf. This statement is therefore entirely
false and unprovable and one can only wonder why such bias would present itself
in such a report when the coelacanth is considered to be “the most endangered
order of animals in the world”1 One shudders to think what the
impact on the coelacanth population has been due to the intensive seismic
testing that has taken place in these areas during the reconnaissance permit
stage!

1 https://en.wikipedia.org/wiki/Coelacanth

Conclusion

The Gulf of
Mexico oil spill can be made an example of how offshore oil and gas drilling
causes detrimental effects to the ecosystem. Do we not learn anything from
history? We are under the impression that all tiers of Government are promoting
the idea of allowing these activities to go ahead without proper and meaningful
consultation with the public communities. This type of reaction from Government
is contradictory because whilst they are promoting tourism with the main focus
on the Sardine shoals, whales and dolphin sighting points, beautiful marine
nurseries, various bird life and small B&BS which thrive on our beautiful
beaches and ocean, they are destroying or allowing the destruction of this
beautiful ocean we have. It seems that the offshore oil and gas project will
only benefit the elite and rich people of society whereby once again the poor
gets dealt a raw deal.